Income Tax for Dividends Acquired from Foreign-Controlled Companies Modernized

In order to implement a stricter taxation framework for foreign-controlled companies, the Ministry of Finance (“Ministry”) has just issued Regulation No. 107/PMK.03/2017 on the Determination of the Moment of Acquisition of Dividends and the Basis for Their Calculation by Domestic Taxpayers for Capital Participation in Overseas Companies (“Regulation 107/2017”).
 
Prior to the issuance of Regulation 107/2017, these same matters were regulated under several provisions (collectively referred to as “Previous Regulations”), specifically: